Respirator Fit Testing is required annually

Your Safety Department^SM

Respirators are an important piece of safety equipment that helps protect the wearer against a variety of harmful airborne agents. OSHA requires the use of respirators to protect employees from breathing contaminated and/or oxygen-deficient air when effective engineering controls are not feasible or are being instituted. But that doesn't mean just anybody can wear a respirator, and in fact, there are times when using a respirator for the wrong purpose can lead to serious injury or death.

Case Study: Many years ago when working as a cargo inspector, I boarded a chemical cargo carrier to inspect a vessel tank prior to loading a chemical that had stringent quality specifications. Confined space activities at that time were not routinely regulated aboard chemical carriers and as a result, many cargo inspectors were put in harm's way due to a lack of training on confined space activities, insufficient instrumentation to test the tank atmospheres, insufficient confined space entry permitting processes, and an over-reliance on the vessel crew to support the confined space entry with hole watches and confirmation that the tanks were under breathable air.

The crew of the vessel was from another country and spoke broken English - 1st clue was to be careful. I was being rushed by the terminal to conduct the inspection since there is always a need for dock space - 2nd clue to be careful. The vessel was dirty, cluttered, and slippery from prior cargo spills on the deck - 3rd clue is to be careful. Something provoked me to conduct a deck-level inspection before an entry was attempted. And, I failed the tank as it contained remnants of a prior cargo of kerosene. This was something that would take quite some time to correct and would probably cause the vessel to have to depart the dock. I was reporting this to the supervisor of the terminal when a commotion started on the deck of the vessel. One of the crew had been instructed to enter the tank to start cleaning the prior cargo residue in an attempt to get inspected before the vessel was forced to leave the dock. The crew member had fallen from a ladder inside the tank. It became immediately clear to the crew that the tank, which I was about to enter to inspect a moment ago, was under nitrogen. The crew member had a cartridge respirator on, but cartridge respirators still require breathable air and are the wrong tool to use when entering tanks with deficient air. The rescue was a successful but painful one for the crew member.

When NOT to wear a respirator

1) When you have not had Medical Clearance to wear a respirator. Medical clearance is required through the submission of a Medical Evaluation Questionnaire. This is conducted by a licensed health care professional (PLHCP) to ensure that the wearer has no medical conditions which would preclude the use of a respirator.

2) When you have not been properly trained on the intended use of the respirator, its limitations, how to don and doff the respirator and how to store and maintain the respirator.

3) When you have not been fit tested to the same make, model, and size of the respirator that you will use in the field. These first three items should be conducted together and on an annual basis in order to refresh the training and to ensure a good-fitting respirator is available for use.

4) When you do not meet the requirements for achieving a good seal on the respirator i.e. unshaven face, or wearing of articles that could cause gaps in the mask that prevent it from sealing. The hair from an unshaven face is like the prongs on a brush lifting the sealing surface of the respirator up and allowing contaminated air into the breathing zone. Shave at least every 24 hours or earlier if needed.

5) When you do not know the contaminant level you are trying to protect yourself from - wrong cartridge type or limitations on the amount of contaminant levels that the cartridge is intended for. Check the cartridge charts from your PPE supplier to ensure you are using the right cartridges for the job.

6) When you have not replaced the filtering cartridges after reaching its useful life. How many people skimp on this very important step? What is the use of doing all of the above if you fail to change the cartridges because of cost concerns? Change them when due.

7) Do NOT wear a cartridge respirator in a space that is not under breathable air. It was not designed for this. Instead, use a Self Contained Breathing Apparatus (SCBA).

Thought Provoking Question 1 - Are there other times when we should NOT wear a respirator that has not been listed above? Please share with our readers.

Respirator fit testing and respirator safety training requirements

Your Safety Department^SM

How would your organization measure up against this standard? Can you afford to be out of compliance? What if it were you who was required to wear a respirator?

According to a study issued by the Bureau of Labor Statistics, 12% of the manufacturing establishments inspected were found to have violated the Respiratory Protection Standard, and of those establishments that underwent health inspections, 22% received Respiratory Protection Violations.

OSHA’s respiratory protection standard took effect on October 5, 1998, and it has over 150 separate provisions within the 13 major sections of the Standard—1910.134(a) to 1910.134(m).

In brief, these are the RP standard’s requirements for employers:

1. Employers must provide respirators and respirator safety training where needed to protect workers’ health.

2. When respirators are required, employers must establish a written RP program that assures that the activities below will be carried out.

3. When employees wear respirators when they are not required to, the employer must establish a partial RP program to ensure that respirator use itself does not harm the worker.

4. Employers must assess whether respirators are needed and provide the appropriate type.

5. Employers must make sure that employees are medically fit to wear respirators and that tight-fitting respirators have the proper respirator fit test.

6. Employers must ensure that workers wear their respirators appropriately and that equipment is properly cleaned and maintained.

7. Employers must provide safety training to workers to use respirators properly.

8. Employers must keep records to document that the preceding steps have been carried out and periodically evaluate their RP program